The


U.S.
Department
of
Housing
and
Urban
Development
(HUD)’s
Office
of
Policy
Development
and
Research
is
seeking
public
comment
related
to
application
and
origination
documents
for
the


Federal
Housing
Administration
(FHA)-backed
Home
Equity
Conversion
Mortgage
(HECM)
program,
according
to
a

notice
published
this
week
in
the
Federal
Register.

Two
key
documents
are
at
the
center
of
the
proposed
changes.
The
first
is
for
the
HECM
anti-churning
disclosure,
which
is
designed
to
protect
borrowers
from
unnecessary
loan
refinancing.
The
newly
proposed
version
has
received
several
key
revisions.

These
include
wholesale
revisions
to
the
lender
table
for
the
best
estimate
of
the
total
cost
of
the
refinancing
to
the
borrower,
as
well
as
increases
to
the
borrower’s
principal
limit.
It
also
adds
the
lender’s
certification,
revises
the
borrower’s
acknowledgment
and
includes
“a
warning
of
the
actions
that
may
be
taken
against
anyone
who
knowingly
submits
a
false
claim
or
makes
a
false
statement.”

HUD
also
seeks
to
transition
away
from
the
discontinued


Fannie
Mae
Form
1009,
the
residential
loan
application
for
reverse
mortgages,
to
Form
1003,
the
Uniform
Residential
Loan
Application
(URLA).

Form
1003
“is
also
used
in
the
mortgage
industry
by
government
sponsored
enterprises
to
originate
conventional
mortgages,”
the
notice
stated.

HUD
also
plans
to
replace
its
use
of
some
internal
forms
and
one
used
in
conjunction
with

U.S.
Department
of
Veterans
Affairs
(VA)
loans,
the
notice
said.

In
particular,
HUD
Form
92900–C
is
designed
to
“collect
loan-level
data
that
is
needed
for
insuring
purposes
and
not
found
on
Fannie
Mae
form
1003,”
according
to
the
notice.

Additionally,
the
standard
loan
application
to
originate
a
HECM
include
Fannie
Mae
Form
1003,
HUD
Form
92900-C
and
Fannie
Mae
Form
1103,
the
latter
of
which
is
a
supplemental
consumer
information
form
that
has
been
adopted
by
the
mortgage
industry.

In
a
previous
interview
with
RMD,


loanDepot
national
reverse
sales
manager
Lisa
Moriello
specifically
cited
the
ongoing
use
of
the
Fannie
Mae
Form
1009
as
something
she
hoped
HUD
would
address.

“Why
are
we
on
a
1009?
And
I
don’t
say
that
because
it’s
a
bad
tool,”
she
said

in
April
2023.
“It’s
not
a
bad
tool.
But
anything
that
the
mortgage
industry
has
created
to
make
it
easier
for
borrowers
has
been
created
to
work
with
the
1003.”

The
1003
is
also
aging
but
has
garnered
more
attention
from
mortgage
service
providers,
Moriello
said
at
the
time.

“Not
really
having
the
1003
and
the
1009
talk
to
each
other,
you
can’t
export
one
to
the
other,”
she
said.
“By
not
updating
the
1009
that
we’re
using,
there
are
tools
that
I’m
blessed
I
can
work
with
in
my
system
and
then
transfer
them
in
cutting
[through]
a
lot
of
things
that
my
borrowers
would
have
to
provide
me
with,
because
I
have
tools
built
in
with
the
1003.
So,
I
would
like
to
see
them
either
talk
to
each
other
or
some
kind
of
upgrade
happen.”

Comments
on
the
proposal
are
due
by
April
26,
2024.
The
notice
features
instructions
on
the
process
that
interested
parties
can
follow
to
submit
comments
prior
to
the
deadline.

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